F?K’
OFFICE
OF
THE
ATTORNEY
GENERAL
JIJj,
STATE
OF
ILLINOIS
C.
20o,g
Lisa
Madigan
UtlOfl
ontrjOlS
ATTORNEY
GENERAL
July 29,
2009
1
John
T
Therriault,
Assistan
Crk
01
N
‘:
Illinois
Pollutiàn
Control
Board
(
James
R. Thompson
Center,
Ste.
11-500
100 West
Randolph
Chicago,
Illinois
60601
Re:
People
v.
Waste
Hauling
Landfill,
Inc.,
et
a!
Dear Clerk:
Enclosed
for
filing
please
find
the
original
and
ten
copies
of a Notice
of
Filing,
Entry
of
Appearance
and
Complaint
in regard
to the
above-captioned
matter.
Please
file
the
originals
and
return
file-stamped
copies
to
me
in
the enclosed,
self-addressed
envelope.
Thank
you
for
your
cooperation
and consideration.
Very
truly
yours,
V
4
(2”
Environmental
Buu
500
South
Second
Street
Springfield,
Illinois
62706
(217)
782-9031
JLMfpjk
Enclosures
500
South Second
Street, Springfield,
Illinois
62706 • (217)
782-1090
• TrY:
(877)
844-5461
• Fax: (217)
782-7046
100
West Randolph
Street,
Chicago,
Illinois
60601
• (312)
814-3000
• TTY:
(800)
964-3013
• Fax:
(312)
814-3806
BEFORE
THE
ILLiNOIS
POLLUTION
CONTROL
BOARD
WASTE
HAULING
LANDFILL,
INC.,
JERRY
CAMFIELD,
A.
E. STALEY
MANUFACTURING
CO.,
ARCHER
DANIELS
MIDLAND,
INC.,
ARAMARK
UNIFORM
SERVICES,
INC., BELL
SPORTS,
INC., BORDEN
CHEMICAL
CO.,
BRIDGESTONE/FIRESTONE,
INC., CLIMATE
CONTROL,
INC.,
CATERPILLAR,
INC., COMBE
LABORATORIES,
INC., GENERAL
ELECTRIC
RAILCAR
SERVICES
CORPORATION, P &
H
MANUFACTURING,
INC.,
TRINITY
RAIL
GROUP,
INC.,
TRIPPLE
S
REFINING
CORPORATION,
and ZEXEL
ILLINOIS,
INC.,
Respondents.
CLERK’S
OFFIC
NOTICE
OF FILING
To:
WASTE
HAULING
LANDFILL,
INC.
do Jerry
Camfield,
Sr.
2938 Oakmont
Drive
Decatur,
IL
62521
JERRY
CAMFIELD,
SR.
2938
Oakmont
Drive
Decatur,
IL 62521
A.
E. STALEY
MANUFACTURING
Co.
do C
T
Corporation
System
208
South
LaSalle
St.,
Suite
814
Chicago,
IL
60604
ARCHER DANIELS
MIDLAND,
INC.
c/o C
T
Corporation
System
208 South
LaSalle
St.,
Suite
814
Chicago,
IL 60604
CLIMATE
CONTROL,
INC.
do
Charles
A. Demirjian,
R.A.
225 N.
Water
Street
Decatur,
IL
62523
ARAMARK
UN[FORM
SERVICES,
INC.
C T
Corporation
System
208
South
LaSalle
St.,
Suite 814
Chicago,
IL 60604
BELL
SPORTS,
INC.
do
Illinois
Corporation
Service
801
Adlai Stevenson
Dr.
Springfield,
IL 62703
BORDEN
CHEMICAL
CO.
do
Prentice
Hall Corporation
33 North
LaSalle
St.
Chicago,
IL 60602
BRIDGESTONE
FIRESTONE,
INC.
c/o C
T
Corporation
System
208 South
LaSalle
St., Suite
814
Chicago,
IL
60604
CATERPIILLAR,
INC.
do
C
T Corporation
System
208 South LaSalle
St.,
Suite 814
Chicago,
IL 60604
PEOPLE
OF THE
STATE
OF
ILLINOIS,
)
)
Complainant,
)
vs.
)
PCBNo.
)
(Enforcement)
)
)
)
)
)
)
)
)
)
)
)
)
JUL
30
20Q
STPT°’
ILUNOIS
pajtiOfl
Cofltr0
board
1
COMBE LABORATORIES,
INC.
do
C
T Corporation
System
208 South
LaSalle St., Suite
814
Chicago, IL 60604
P & H MANUFACTURING,
INC.
604 S. Lodge
P.O. Box
549
Shelbyville,
IL 62565
TRIPLE
REFINING
CORPORATION
do
C T Corporation System
208 South
LaSalle St., Suite 814
Chicago,
IL
60604
GENERAL ELECTRIC
RAILCAR
SERVICES
CORPORATION
do C T
Corporation System
208 South LaSalle
St., Suite 814
Chicago,
IL 60604
TRINITY
RAIL
GROUP, INC.
do C T
Corporation
System
208
South
LaSalle
St.,
Suite
814
Chicago, IL 60604
ZEXEL
ILLINOIS, INC.
do Kathy Carter,
R.A.
625 Southside Drive
Decatur,
IL 62525
PLEASE
TAKE
NOTICE
that
on this date I mailed
for
filing
with
the
Clerk
of the Pollution
Control
Board
of
the State of Illinois,
a COMPLAINT,
a copy
of which
is attached
hereto
and herewith
served
upon
you. Failure to
file
an
answer
to
this Complaint
within
60 days
may have severe consequences.
Failure
to
answer
will
mean
that all
allegations
in this Complaint
will
be
taken
as
if admitted
for
purposes
of this
proceeding. Ifyou
have any
questions about this procedure,
you
should contact
the
hearing officer
assigned
to
this proceeding,
the Clerk’s
Office or an attorney.
FURTHER,
please
take notice that
financing
may
be
available,
through
the Illinois Environmental
Facilities
Financing
Act,
20 ILCS
35
15/1
(2006), to
correct
the pollution alleged
in the Complaint
filed in
this
case.
Respectfully submitted,
PEOPLE
OF
THE STATE
OF ILLINOIS
LISA MADIGAN,
Attorney General
of
the
State
of Illinois
2
500 South Second Street
Springfield, Illinois 62706
217/782-9031
Dated: July
29,
2009
3
MATTHEW J. DUNN,
Chief
Environmental Enforcement/Asbestos
Litigation Division
BY:&
///
JAMES
/A
L. MORG
(Z
Sr.
Assistant Attrn’
General
Environmental Bureau
CERTIFICATE
OF
SERVICE
I hereby certify
that I did
on
July 29,
2009,
send
by
certified mail, with
postage thereon
fully
prepaid,
by depositing
in a United
States Post
Office
Box a
true and correct
copy of the
following instruments
entitled
NOTICE OF FILING,
ENTRY
OF APPEARANCE
and
COMPLAINT:
To:
WASTE HAULING
LANDFILL,
INC.
do Jerry Camfield,
Sr.
2938
Oakmont Drive
Decatur,
IL 62521
JERRY CAMFIELD,
SR.
2938
Oakmont Drive
Decatur,
IL
62521
A.
E.
STALEY MANUFACTURING
CO.
do C T Corporation
System
208
South LaSalle
St.,
Suite
814
Chicago, IL
60604
ARCHER
DANIELS
MIDLAND, INC.
do C T Corporation
System
208
South LaSalle
St., Suite 814
Chicago, IL
60604
CLIMATE
CONTROL,
INC.
do Charles A.
Demirjian,
R.A.
225
N.
Water Street
Decatur, IL
62523
COMBE
LABORATORIES,
INC.
do
C
T Corporation
System
208
South LaSalle
St., Suite
814
Chicago, IL
60604
ARAMARK
UNIFORM
SERVICES,
INC.
C T
Corporation
System
208 South LaSalle
St.,
Suite 814
Chicago,
IL 60604
BELL
SPORTS,
INC.
do
Illinois
Corporation Service
801 Adlai Stevenson
Dr.
Springfield,
IL 62703
BORDEN CHEMICAL
CO.
do
Prentice Hall Corporation
33 North LaSalle
St.
Chicago, IL
60602
BRIDGESTONE
FIRESTONE,
INC.
do C
T Corporation
System
208 South LaSalle
St.,
Suite
814
Chicago, IL 60604
CATERPIILLAR,
INC.
do
C T
Corporation
System
208
South
LaSalle St., Suite
814
Chicago, IL
60604
GENERAL ELECTRIC
RAILCAR
SERVICES
CORPORATION
do C T Corporation
System
208 South LaSalle
St.,
Suite
814
Chicago,
IL 60604
P & H MANUFACTURING,
INC.
604
S.
Lodge
P.O.
Box 549
Shelbyville,
IL 62565
TRIPLE REFINING
CORPORATION
c/o C
T Corporation
System
208 South LaSalle St., Suite
814
Chicago, IL 60604
TRINITY
RAIL GROUP, INC.
do
C T Corporation System
208 South LaSalle
St.,
Suite
814
Chicago, IL
60604
ZEXEL ILLINOIS, INC.
do Kathy Carter, R.A.
625 Southsicle Drive
Decatur, IL 62525
and the original and ten
copies
by First Class Mail
with postage thereon fully prepaid of the
same
foregoing instrument(s):
To:
John T. Therriault, Assistant Clerk
Illinois
Pollution Control Board
James R. Thompson
Center
Suite 11-500
100
West Randolph
Chicago, Illinois 60601
‘JAMES L.
MORGAN/
Sr.
Assistant Attorney General
This
filing
is submitted on recycled paper.
BEFORE
THE
ILLINOIS
POLLUTION CONTROL
BOARD
WASTE HAULING
LANDFILL, INC.,
JERRY
CAMFIELD,
A. E. STALEY
MANUFACTURING
CO.,
ARCHER
DANIELS
MIDLAND,
INC.,
ARAMARK
UNIFORM
SERVICES, INC.,
BELL
SPORTS,
INC.,
BORDEN
CHEMICAL
CO.,
BRIDGESTONE/FIRESTONE,
INC., CLIMATE
CONTROL,
INC.,
CATERPILLAR,
INC., COMBE
LABORATORIES,
INC.,
GENERAL
ELECTRIC
RAILCAR
SERVICES
CORPORATION,
P &
H
MANUFACTURING,
INC.,
TRINITY RAIL
GROUP,
INC.,
TRIPPLE
S
REFINING
CORPORATION,
and
ZEXEL ILLINOIS,
INC.,
)
Respondents.
ENTRY
OF
APPEARANCE
On
behalf of
the Complainant,
PEOPLE
OF
THE STATE
OF
ILLINOIS,
JAMES
L.MORGAN,
Sr.
Assistant Attorney
General
of the State of
Illinois, hereby enters
his
appearance
as
attorney of
record.
500
South
Second Street
Springfield,
Illinois 62706
217/782-9031
Dated:
July 29,
2009
Respectfully
submitted,
PEOPLE
OF THE
STATE
OF ILLINOIS,
LISA MADIGAN
Attorney
General
of
the
State
of Illinois
MATTHEW
J. DUNN,
Chief
Environmental
Enforcement/Asbestos
Sr.
Assistant
Attorney
General
PEOPLE OF
THE STATE OF ILLINOIS,
)
V
)
Complainant,
V
)
)
vs.
)
PCBNo.
)
(Enforcement)
)
)
)
)
)
)
)
)
)
)
)
)
L
30200
pollution
cco4Lf
N,
Litigation
Division
BEFORE
THE ILLINOIS POLLUTION CONTROL BOARD
MACON
COUNTY, ILLINOIS
PEOPLE OF THE STATE OF ILLINOIS,
)
)
Complainant,
)
v.
)
PCBNO.
‘i
WASTE HAULING LANDFILL, INC., JERRY
)
(Cost Recovery)
CAMFIELD, A. E. STALEY MANUFACTURING
)
CO., ARCHER DANIELS MIDLAND, INC.,
)
ARAMARK UNIFORM
SERVICES,
INC., BELL
)
SPORTS, INC.,
BORDEN
CHEMICAL, CO.,
)
BRIDGESTONE/FIRESTONE, INC.,
CLIMATE
)
CONTROL, INC., CATERPILLAR INC., COMBE
)
LABORATORIES,
INC., GENERAL
ELECTRIC
)
R
E
C
E
V
ED
RAILCAR SERVICES
CORPORATION,P
&
H
)
CLERK’S
OFFICE
MANUFACTURING, INC.,
TRINITY RAIL GROUP,
)
.,nng
INC., TRIPLE
S
REFINING CORPORATION,
and
)
LUU
ZEXEL
ILLINOIS, INC.,
)
STATh
OF
ILLINOIS
pollution
Control
Board
Respondents.
COMPLAINT
Complainant,
PEOPLE OF THE STATE OF
ILLINOIS, by LISA MADIGAN, Attorney
General
of the State of
Illinois, complains of Respondents,
WASTE HAULING LANDFILL, INC., JERRY
CAMFIELD,
AE STALEY
MANUFACTURING
CO.,
ARCHER DANIELS MIDLAND, INC.,
ARAMARK
UNIFORM
SERVICES, INC., BELL SPORTS, INC., BORDEN CHEMICAL, CO.,
BRIDGESTONE/FIRESTONE, INC.,
CLIMATE CONTROL, INC.,
CATERPILLAR INC.,
COMBE
LABORATORIES, INC.,
GENERAL ELECTRIC RAILCAR
SERVICES CORPORATION,
P
&
H
MANUFACTURING, INC.,
TRIPLE S REFINING
CORPORATION, TRINITY RAIL GROUP, [NC.,
and ZEXEL
ILLINOIS,
INC. as follows:
COUNT I:
COST RECOVERY
1.
This
Complaint is brought by the
Attorney General on her own motion and at the
request
of
the Illinois
Environmental
Protection
Agency
(“Illinois EPA”), pursuant to the terms and provisions
of
1
Title VIII
(Sections 30-34)
of the Illinois
Environmental
Protection
Act (“Act”),
415 ILCS
5/30-34
(2008).
2.
The
Illinois
EPA
is
an agency of
the State
of
Illinois created
by
the
Illinois
General
Assembly
in Section 4
of
the
Act, 415
ILCS 5/4 (2008),
and charged,
inter alia,
with the duty
of
enforcing
the Act
in proceedings
before the Illinois
Pollution
Control Board
(“Board”).
3.
This Complaint
is brought
pursuant
to Section 22.2(f)-(k)
of
the Act, 415
ILCS 5/22.2(f)-
(k)
(2008).
4.
Respondent,
Waste
Hauling Landfill,
Inc.,
is
a
corporation
formerly
authorized to
do
business
in the
State
of
Illinois
and
is a
person
as
defined
in Section
3.315
of the Act,
415
ILCS 5/3.315
(2008).
Waste
Hauling Landfill,
Inc., operated
the Waste
Hauling
Landfill (the
“Landfill”),
a former
sanitary landfill
located
in
the Northwest
Quarter
of the Northwest
Quarter
of Section
26, Township
16
North,
Range
1 East (Blue
Mound Township),
Macon
County,
Illinois.
5.
Respondent,
Jerry
Camfield,
is an
individual
and
is
a
person
as defined
in Section
3.3
15
of the
Act,
415 ILCS 5/3.3
15 (2008).
Jerry Camfield
owned
Waste
Hauling
Landfill,
Inc.,
and personally
directed
itsoperations.
6.
Respondent,
A. E. Staley
Manufacturing
Co.,
is a
corporation
authorized
to
do business
in the State
of Illinois
and is
a
person
as
defined in Section
3.315
of the Act,
415 ILCS
5/3.315
(2008).
A.
E.
Staley
Manufacturing
Co.,
sent wastes
to the
Landfill
during
its
operating
life
and those
wastes
contained
hazardous substances.
7.
Respondent,
Aramark
Uniform
Services,
Inc.,
is a
corporation
no longer authorized
to
do
business
in the
State of Illinois
and is a
person as
defined
in Section
3.3
15 of the
Act,
415
ILCS
5/3.3 15
(2008).
Aramark
Uniform Services
is
a
successor
to
Means Uniform
Services.
Means
Uniform
Services
sent wastes
to
the
Landfill
during its
operating
life and
those wastes
contained
hazardous
substances.
2
8.
Respondent, Archer
Daniels Midland,
Inc.,
is
a
corporation
authorized
to do
business
in
the State
of Illinois
and is a person as
defined in
Section 3.3
15 of
the Act,
415
ILCS
5/3.315
(2008).
Archer
Daniels Midland,
Inc., sent wastes
to the Landfill during
its operating life and those
wastes
contained
hazardous substances.
9.
Respondent, Bell Sports,
Inc., is a
corporation authorized
to do
business in the
State of
Illinois
and is
a
person as defined
in Section 3.3 15
of the Act, 415
ILCS 5/3.3 15 (2008).
Bell Sports,
Inc., sent wastes to
the
Landfill
during its operating life
and those
wastes
contained
hazardous
substances.
10.
Respondent,
Borden Chemical Co.,
is
a
corporation
authorized
to do business
in
the
State
of Illinois and
is
a
person
as
defined in Section 3.3
15
of the Act,
415 ILCS 5/3.3 15 (2008).
Borden
Chemical
Co.,
sent wastes
to
the Landfill
during its
operating life and those
wastes contained hazardous
substances.
11.
Respondent,
Caterpillar
Inc., is
a
corporation
authorized
to do
business in the
State of
Illinois
and is
a
person as
defined
in Section 3.3 15
of
the Act, 415
ILCS 5/3.3
15
(2008). Caterpillar
Inc.
sent
wastes to
the
Landfill
during
its operating
life
and
those wastes
contained hazardous
substances.
12.
Respondent, Climate
Control,
Inc.,
is
a
corporation
authorized
to do business
in the
State
of Illinois and
is a
person
as
defined in Section
3.3
15 of
the Act,
415 ILCS
5/3.3 15 (2008). Climate
Control,
Inc.,
sent
wastes
to the Landfill during
its operating
life and those
wastes contained
hazardous
substances.
13.
Respondent, Combe
Laboratories,
Inc., is a
corporation
authorized to
do
business
in the
State of
Illinois and
is
a
person as defined
in Section
3.3 15
of the
Act, 415 ILCS 5/3.3 15
(2008).
Combe
Laboratories,
Inc.,
sent wastes to
the Landfill during its
operating life
and
those
wastes
contained
hazardous
substances.
3
14.
Respondent,
Bridgestone/Firestone
Inc., is
a
corporation
authorized to
do
business
in
the
State
of
Illinois and
is a
person
as
defined
in Section 3.3
15 of the Act,
415 ILCS
5/3.3 15
(2008).
Bridgestone/Firestone
Inc., is
a successor
to Firestone
Tire
&
Rubber
Company.
Firestone
Tire
&
Rubber
Company,
sent wastes
to the
Landfill during
its operating
life
and those
wastes contained
hazardous
substances.
15.
Respondent,
General Electric
Railcar
Services
Corporation,
is
a corporation
authorized
to do business
in the State
of
Illinois
and is a
person
as
defined
in
Section
3.315
of the Act, 415
ILCS
5/3.3
15 (2008).
General
Electric
Railcar
Services
Corporation
acquired
the
North
American
Car
Corporation.
The North
American
Car
Corporation
sent
wastes
to
the
Landfill
during its
operating
life
and those
wastes
contained
hazardous
substances.
16.
Respondent,
Triple
S
Refining
Corporation,
is a corporation
authorized
to
do business
in
the
State
of Illinois
and is
a person as
defined in
Section
3.3 15 of
the Act,
415
ILCS 5/3,3
15 (2008).
Triple
S
Refining
Corporation
is
a
successor to
Kerr-McGee
Refining
Corporation.
Kerr-McGee
Refining
Corporation
sent wastes
to
the Landfill
during its operating
life
and
those
wastes contained
hazardous
substances.
17.
Respondent,
P & H Manufacturing,
Inc.,
is a corporation
authorized
to do
business in
the
State of
Illinois and
is a
person
as defined
in
Section
3.3 15 of the
Act, 415 ILCS
5/3.3 15
(2008). P
& H
Manufacturing,
Inc.,
sent
wastes to
the Landfill
during
its operating
life and
those wastes
contained
hazardous
substances.
18.
Respondent,
Trinity
Rail Group,
Inc., is a
corporation
authorized
to do business
in the
State of
Illinois
and is
a
person
as defined
in
Section 3.3
15 of the Act,
415 ILCS
5/3.3 15 (2008).
Trinity
Rail
Group, Inc.,
acquired
Thrall Car
Manufacturing
Co.,
which
had previously
acquired
the rail
car
division
of
Portec,
Inc.
Thrall Car
Manufacturing
Co.
and
the
rail car division
of Portec,
Inc.,
sent wastes
to
the Landfill
during
its
operating
life
and
those wastes
contained
hazardous
substances.
4
19.
Respondent, Zexel Illinois,
Inc., is a corporation authorized to do business in the State
of
Illinois
and is a
person
as
defined
in Section 3.315 of the Act, 415 ILCS 5/3.315 (2008). Zexel Illinois,
Inc., acquired Borg-Warner Corp. Borg-Warner Corp.
sent
wastes
to
the Landfill during its operating
life
and those
wastes
contained
hazardous
substances.
20.
Section 22.2 of the Act, 415 ILCS
5/22.2
(2008),
provides that:
***
f.
Notwithstanding any other provision or rule of law, and subject only to the defenses
set
forth in subsection
(j)
of this Section, the following persons shall
be
liable for all costs of
removal or remedial action incurred
by
the
State
of Illinois or any unit of local government
as
a
result of a release or substailial threat
oa
release ofhazrdous substance
or
pesticide:
1.
the owner
and operator of a facility or vessel
from which
there is
a release or substantial threat of a release of a
hazardous
substance
or
pesticide;
2.
any person who at the time of disposal, transport, storage or
treatment of a hazardous substance or pesticide owned or operated
the
facility or vessel used for such disposal, transport, treatment
or storage
from which there was
a
release or substantial threat of a release of a
hazardous substance or pesticide;
3.
any person who
by
contract, agreement,
or
otherwise
arranged
for disposal or treatment, or arranged with
a
transporter for
transport
for
disposal
or
treatment,
of
such
hazardous substances owned or possessed
by such
person,
by
any other
party
or entity, at any
facility,
*
*
*,
owned
or operated
by
another party or entity and containing such hazardous
substances,
* **
21.
The wastes
and
other
materials disposed of at the Landfill include hazardous substances
as
defined by 3.14 of the
Act,
415 ILCS
5/3.14
(2008).
22.
The State
has incurred and will continue to incur removal costs, as defined by the Act,
associated
with the releases
and
threatened
releases
of hazardous substances
at
the Facility.
23.
Respondents
are each
a
responsible
party as
described in Section 22.2(f)(1)-(2) of the
Act,
415 ILCS
4/22.2(f)( 1 )-(2).
Respondents
are
each liable for past, present, and future removal costs,
as
defined by
the Act,
incurred
by the
State
resulting or
arising out of the releases and threatened releases
5
at the
Landfill.
PRAYER
FOR RELIEF
WHEREFORE, Complainant,
the PEOPLE OF THE STATE OF
ILLINOIS, respectfully
request
that
the
Board enter an order against the Respondents:
A.
Authorizing
a hearing in this matter
at
which time
the
Respondents
will be required
to
answer the
allegations herein;
B.
Finding the Respondents, Waste Hauling Landfill,
Inc., Jerry Camfield, A E Staley
Manufacturing Co.,
Archer Daniels Midland,
Inc., Aramark Uniform Services, Inc., Bell Sports, Inc.,
Borden Chemical, Co., Bridgestone/Firestone Inc., Climate Control, Inc., Caterpillar Inc.,
Combe
Laboratories,
Inc., General Electric Railcar Services Corporation, P
&
H Manufacturing,
Inc., Triple
S
Refining Corporation,
and Trinity Rail Group, Inc.,
to be
liable for
past,
present,
and future removal
costs, as
defined by the
Act,
incurred
by
the Illinois EPA
as a
result of the releases
and
threatened
releases of
hazardous substances at the
Facility;
C.
Finding Respondents, to be liable for damages equal to
three times the
past,
present,
and
future
removal costs, as
defined by the Act, incurred by the Illinois EPA as a
result
of
the releases
and
threatened
releases
of hazardous substances at the Facility; because
of
the
Respondents’ refusal
to
perform
the work set
forth
in the Section
4(q)
notice issued by
Illinois
EPA;
D.
Awarding
to
Complainant its costs; and
6
E.
Granting such other relief
as the Board may deem appropriate.
Respectfully
submitted,
PEOPLE
OF THE STATE OF
ILLINOIS
LISA MADIGAN,
Attorney General
of the
State
of Illinois,
MATTHEW
J. DUI’JN, Chief
Environmental
Enforcement/Asbestos
Litigation
Division
BY:__________________
THOMAS DAVIS,
Chief
Environmental Bureau
Assistant Attorney General
Of Counsel
James L. Morgan
Assistant Attorney
General
500
South Second Street
Springfield,
Illinois 62706
217/524-7506
Dated:
7